One of the more difficult things for investigators, and firms, to assess is the effectiveness of training programs.
Many firms have extensive training programs in place, but they do not necessarily have systems in place to evaluate the effectiveness of the training program. Training should not be a one-shot deal. It has to be ongoing and dynamic. When there is a deviation, or when someone makes a mistake that leads to some type of deviation, that is generally a symptom of an underlying systemic problem with the training program. It has been my experience that when we examine the cause of a majority of the 483 observations, it includes some element of improper, or inadequate, training. So, when things go wrong, I think firms should use that information to examine, and hopefully improve, their training program. If an operator does something wrong, the problem generally falls to the training program, not that individual operator. If he or she did something wrong, then there are probably other operators out there with similar, inadequate training and management’s response should be to fix the training and assure that everyone is trained properly before another problem arises.
